Mariani Frozen Foods, Inc. v. Commissioner
United States Tax Court
During their fiscal years beginning May 1, 1973, IFTS and LFG each held 40 percent of the outstanding shares of Simarloo, an Australian corporation. Y corporation, a subsidiary of X corporation, held the remaining 20 percent of Simarloo's shares.
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During their fiscal years beginning May 1, 1973, IFTS and LFG each held 40 percent of the outstanding shares of Simarloo, an Australian corporation. Y corporation, a subsidiary of X corporation, held the remaining 20 percent of Simarloo's shares. During its fiscal year ended June 30, 1973, Simarloo sold X corporation shares at a profit of $ A1,200,052. Translated to U.S. dollars, Simarloo's gain was $ 1,595,231, $ 250,016 of which was foreign currency exchange gain attributable to the increase in value of the Australian dollar against the U.S. dollar between the dates on which Simarloo…
1Opinion of the Court
Forrester, Judge:
Respondent determined deficiencies and/or liabilities in petitioners’ Federal income taxes as follows:
Docket No. Petitioners Year Deficiency ending or liability
11129-78 Mariani Frozen Foods, Inc., successor in interest to International Food Technology Service, Inc. 4/30/74 $1,217,489.00
13826-79 Melinda L. Gee Trust, Robert E. 4/30/74 30,374.23 Gee and Kathleen L. Gee, Trustee, 1/3/75 Transferee of L.F.G., Inc.
13827-79 Kathleen E. Gee Trust, Robert E. 4/30/74 $30,374.23 Gee and Kathleen L. Gee, Trustees, 1/3/75 Transferee of L.F.G., Inc.
13828-79 Joel-Ann Foote, Transferee of…
2Cases cited51 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- Fulman v. United StatesSupreme Court of the United States · 1978
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3Cited by9 opinions
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